The IRS Criminal Investigation division has a longstanding practice of considering a taxpayer’s timely, accurate, and complete voluntary disclosure in determining whether or not to pursue criminal prosecution against the taxpayer.
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A previous article on this topic addressed the civil penalties potentially applying to taxpayers who qualify for the Offshore Voluntary Disclosure Program but fail to apply.
When facing off against the IRS for whatever reason, there is always a process for escalation wherein if your case is not resolved you can seek the attention of a higher authority.
Sometimes, it is in the best interest of the taxpayer to make a refund claim instead of file a deficiency action in the Tax Court.
Litigation in the Tax Court is unique among all other forums in that the process involves various pre-trial stipulations made by both parties. In fact, the Tax Court requires litigant to submit to extensive pretrial stipulations, which are embodied in Tax Court Rule 91.